This ICR is
approved. In accordance with OMB guidelines, and in response to
questions raised by GAO in a March 2000 report, EPA has revised the
manner in which burden for outside lab analysis is accounted for.
Prior to 1996, this burden was accounted for in hours, based on the
estimated time for a lab to conduct the required analysis. In 1996,
this burden was converted to monetary costs, based on the fees
charged by independent labs to conduct analyses. Because of the
potential for confusion regarding the interpretation of the
resulting drop in reported hourly burden (although this was
compensated for by an increase in reported cost burden), EPA has
determined that it is appropriate to reconvert this burden back to
hours for purposes of ICR accounting. Since the change in reporting
convention that was reflected in the 1996 ICR renewal did not
correspond to any actual change in requirements, EPA has determined
that it is more straightforward to continue to present all burden
related to lab analysis in hours. This reconversion results in a
1,082,011 increase in reported burden and a corresponding $47.3
million decrease in reported costs in the current ICR. OMB agrees
that this is the most appropriate manner in which to account for
lab analysis burden. The supporting statement for this ICR also
indicates that because of program changes that have occurred since
1996, EPA believes the current burden estimate of 2,847,167 hours
is overstated, and that EPA is currently working on revising this
estimate. OMB welcomes the opportunity to work with EPA to ensure
that the final burden estiamte is accurate and objectively
supported, as required by 5 CFR 1320.8(a)(4). Any revisions to the
burden estimate that reflect only calculation adjustments based on
better or more up-to-date data, or that reflect program changes
made and approved prior to the date of approval of this ICR may be
submitted to OMB for review on form OMB 83-C, Paperwork Reduction
Act Change Worksheet. All such changes should be accompanied by
appropriate documentation showing the reason for the change, the
quantitative effect of the change, and in the case of changes to
existing assumptions, the data or new information on which the
changed assumption is based. As a general rule, changes to burden
calculation assumptions in existing ICRs where the program
requirments have not changed should be based on concrete new
information only, not merely on revised professional
judgement.
Inventory as of this Action
Requested
Previously Approved
09/30/2004
09/30/2004
09/30/2000
2,028,826
0
20,882
2,847,167
0
1,765,156
0
0
47,349,000
This ICR calculates the burden and
costs associated with manag- ing the National Pretreatment Program
mandated by Section 402(a) and 307(b) of the Clean Water Act. This
ICR is a renewal of the current ICR for the National Pretreatment
Program OMB Control No. 2040-0009, ICR no. 0002.08. The
Pretreatment Program is a joint regulatory effort by federal, State
and local authorities to control nondomestic (i.e., industrial and
commerical) sources of pollutants discharged to POTWs. Data are
collected to deter- mine compliance with the regulations.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Information Collection Request for the National Pretreatment Program